Legal Opinion

Hurlbut v. Commissioner

United States Board of Tax Appeals

Decided December 31, 1935No. Docket Nos. 71788, 75494PublishedCited by 1 opinion

Where the respondent fails to show that property of an ancestor received by heirs has any value above encumbrances, there is no transferee liability of the heirs.

1Opinion of the Court

*869OPINION.

Seawell :

Respondent says and contends that under the stipulated and admitted facts the burden imposed upon him by section 602 of the Revenue Act of 1928 has been met and discharged. That the admission that petitioners are the heirs at law of the transferor, the intestate, who had no other valuable assets at the date of his death than those then passing by operation of law to petitioners, and that *870such assets then had a value of $7,500, whereas the taxes herein involved are only in the amount of $3,821.15, respondent claims “ clearly meets respondent’s burden.” He further says in his…

2Cited by1 opinion

  1. Hurlbut v. CommissionerUnited States Board of Tax Appeals · 1935

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